NACHC Statement on CMS Hold Harmless Period to Strengthen Medicaid Work Requirement Systems

For Immediate Release

Nov. 13, 2026

Contact: Michael King, [email protected]

On behalf of Community Health Center (CHC) patients, we welcome CMS' announcement of an optional hold harmless period through June 30, 2027, and its recognition of the challenges states face in implementing Medicaid work requirements. NACHC has advocated for safeguards to protect eligible patients from coverage disruptions, and this announcement is an important step toward that goal. This flexibility will help ensure that patients who remain eligible for Medicaid are not wrongly denied coverage or cut off from care because of paperwork or system errors. 

More than 52 million patients - 1 in 7 Americans, including 1 in 3 in rural areas - rely on CHCs for affordable, comprehensive primary and preventive care. For these patients, losing coverage can mean delayed care, skipped medications, and preventable trips to the emergency room.

NACHC remains deeply concerned that H.R. 1 will jeopardize health coverage for an estimated 4 million CHC patients and cost CHCs $7 billion in increased uncompensated care. The projected impact also includes 5,000-6,000 deaths and the loss of 34,000 CHC jobs - a strain that threatens access to care for every patient who walks through our doors. 

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About NACHC

NACHC's mission is to champion Community Health Centers delivering affordable, effective, comprehensive primary care that is community-driven and improves health for all. For more information, visit www.nachc.org.